Stechauner, Matthew v. Evers, Tony
3:24-cv-00840
| W.D. Wis. | Nov 27, 2024Background
- Matthew C. Stechauner, an inmate at Oshkosh Correctional Institution, alleges his sensitive risk-of-victimization status was disclosed by a correctional officer to other inmates.
- This disclosure led to an incident where another inmate slapped Stechauner’s buttocks, witnessed by other corrections staff, who delayed required reporting and failed to separate victim and perpetrator as mandated by PREA guidelines.
- Stechauner claims he was not promptly given a medical exam or psychological care following the assault, and the institution failed to preserve relevant camera footage.
- Complaints to officials resulted in Stechauner being transferred to a different facility, which he alleges was retaliatory and contrary to PREA requirements.
- The court previously ruled Stechauner’s original complaint improperly joined unrelated claims; he chose to pursue only those relating to the alleged PREA violation and resulting assault in this case.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Disclosure of victimization status | Baxter’s disclosure led to assault, violated rights | Not specified | States claim for failure to protect; may proceed |
| Failure to protect post-assault | Officials kept him with assailant, causing distress | Not specified | States claim; may proceed |
| Denial of medical/psych care | Delay in care amounted to Eighth Amendment violation | Not specified | No claim; no alleged harm shown |
| Retaliatory transfer | Transfer was retaliation for complaints about assault | Not specified | No claim; transfer not shown to be punitive |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (failure to protect under the Eighth Amendment requires deliberate indifference to a substantial risk of serious harm)
- Dale v. Poston, 548 F.3d 563 (7th Cir. 2008) (officials have a duty to protect inmates from harm from other prisoners)
- Mayoral v. Sheahan, 245 F.3d 934 (prison officials must protect prisoners from harm by other inmates)
- McGowan v. Hulick, 612 F.3d 636 (delay in medical treatment can violate the Eighth Amendment if there’s injury)
- Lord v. Beahm, 952 F.3d 902 (risk alone without injury is not actionable under Eighth Amendment)
- Bridges v. Gilbert, 557 F.3d 541 (First Amendment retaliation claim standard)
- Holleman v. Zatecky, 951 F.3d 873 (transfer must be to a more restrictive/dangerous place to be retaliatory)
- Burks v. Raemisch, 555 F.3d 592 (high-ranking officials not liable unless personally involved)